Citation[]
Federal Communications Commission, Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; E911 Requirements for IP-Enabled Service Providers, CG Docket No. 03-123, WC Docket No. 05-196, Second Report and Order and Order on Reconsideration, 24 FCC Rcd 791 (Dec. 19, 2008) ("Second Internet-based TRS Order").
Overview[]
In the Second Internet-based TRS Order, released on December 19, 2008, the Commission addressed issues included in the First Internet-based TRS Order’s Further Notice of Proposed Rulemaking.[1] Among other things, the Commission provided existing users a three-month “registration period,” during which iTRS users could select a default provider, provide their Registered Location, and obtain their new ten-digit NANP telephone numbers, followed by a three-month “permissive calling period,” which ended on November 12, 2009.[2]
During these registration and permissive calling periods, existing iTRS users were able to place and receive calls via the method used prior to implementation of the Commission’s numbering plan. At the conclusion of the permissive calling period, however, providers were required to register any unregistered user before completing a non-emergency VRS or IP Relay call.
The Commission also found that, to further the goals of the numbering system, “Internet-based TRS users should transition away from the exclusive use of toll-free numbers” and required all iTRS users to obtain “ten-digit geographically appropriate numbers, in accordance with the FCC's numbering system.”[3] The Commission reasoned that local numbers, and not toll-free numbers, should be used when contacting Public Safety Answering Points (PSAPs).[4] Accordingly, the Commission stated that a user’s toll-free number must be mapped to the user’s local, geographically appropriate number.[5] Moreover, the Commission found that, just as voice telephone users are responsible for the costs of obtaining and using toll-free numbers, the TRS fund should not compensate providers for the use of toll-free numbers by iTRS users.[6]
References[]
- ↑ The Commission addressed issues related to 911, registration, toll-free numbers, eligibility and verification procedures, assignment of numbers, numbering costs, consumer protection, and various petitions for reconsideration and clarification.
- ↑ Id. at 801, 802, ¶¶21, 23. On June 15, 2009, the FCC's Consumer and Governmental Affairs Bureau extended from June 30, 2009 to November 12, 2009 the end date for the permissive calling period during which Internet-based Telecommunications Relay Service providers were permitted to continue to complete the non-emergency calls of unregistered users. See FCC, Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; E911 Requirements for IP-Enabled Service Providers, CG Docket No. 03-123, WC Docket No. 05-196, Order, 24 FCC Rcd 8000 (CGB 2009).
- ↑ See 24 FCC Rcd at 806–07, ¶32.
- ↑ Id.
- ↑ Id. The Second Internet-based TRS Order required that iTRS users be assigned ten-digit, geographically appropriate numbers — numbers within the users’ rate centers — and prohibited any workaround solutions. See id. at 805, ¶28. However, on November 5, 2009, the Wireline Competition Bureau granted iTRS providers a temporary waiver of the prohibition in the Second Internet-Based TRS Order against assigning a geographically approximate number to a user in cases where a provider cannot gain access to a number in the user’s rate center. Accordingly, during the waiver period, iTRS providers may use their best efforts to obtain a “geographically approximate” number as close to a user’s rate center as possible. See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; E911 Requirements for IP-Enabled Service Providers, CG Docket No. 03-123, WC Docket No. 05-196, Order, 24 FCC Rcd 13645, 13650–51, ¶¶9, 11 (CGB/WCB 2009).
- ↑ See Second Internet-based TRS Order, 24 FCC Rcd at 815–16, ¶¶52–54. The Commission permitted iTRS providers to provide toll-free numbers at their own cost. See id. at 815 n.189 (“We note that, to the extent that Internet-based TRS providers do not obtain compensation from the Fund for the charges associated with these toll-free numbers today, this Order simply preserves the status quo.”).